American Heart Association: A clean label doesn't necessarily make for a 'healthy' product

Consumer research indicates that for many shoppers, ‘healthy,' is all about foods that are organic, minimally processed, natural, non-GMO, or free of artificial ingredients. But such factors should not be included in the legal criteria for 'healthy' claims on pack, argues the American Heart Association (AHA).

In comments​​ submitted to the FDA as part of its probe​ into 'healthy' claims on food labels, AHA president Steven R. Houser, PhD, observed: “Consumers’ views of health and wellness are becoming more inclusive as they are defined by more than nutrient content. ​

“For example, respondents in the IFIC 2016 Food and Health survey reported that a healthy food is defined, in part, by being organic, fresh, unprocessed, natural, free of artificial ingredients and additives, and having few ingredients.”​

But he added: “Definitions for many of these factors are not clearly defined in law nor agreed upon by stakeholders. Furthermore, and perhaps more importantly, there is not sufficient scientifically sound evidence linking them to health outcomes.”​

Criteria should not vary on a category-by-category basis​

That said, the FDA should move away from a ‘healthy’ definition that is narrowly focused on a handful of nutrients “to one that requires foods to meet both food and nutrient criteria,” ​he said.

“We support reserving ‘healthy’ for products that satisfy the 2015‐2020 Dietary Guidelines for Americans’ recommendation to consume a variety of nutrient‐dense foods and beverages, i.e., those that ‘provide vitamins, minerals, and other substances that contribute to adequate nutrient intakes or may have positive health effects, with little or no solid fats and added sugars, refined starches, and sodium…ideally…in forms that retain naturally occurring components.’​

“We believe this to be distinct from products that may be ‘better‐for‐you’ choices (compared to other similar products within a given category, i.e., relative comparisons), but that do not have an overall composition and nutrient profile consistent with the intent of the dietary guidelines. If consumers selected foods only from the latter category, their overall eating patterns would likely fail to achieve recommendations.”​

“Consumer understanding of health and nutrition can be influenced by non-authoritative sources which may be in direct conflict with established dietary guidance.”​

General Mills (in comments submitted to the FDA as part of its probe into 'healthy' label claims)​

AHA: Added sugars should be limited in products making ‘healthy’ claims​

As for some of the main bones of contention​​ highlighted in industry comments, the AHA believes that added sugars should be controlled in ‘healthy’ foods, and that limits on saturated fat should remain part of the criteria, although it recommends removing total fat limits.

On the thorny issue of whether fortified foods should be able to make ‘healthy’ claims, the AHA believes that “the​ beneficial nutrients that establish a food’s ‘healthy’ claim should occur intrinsically in food,”​ but then goes on to add that exceptions can be made.

“This does not necessarily mean that fortified foods cannot bear the “healthy” claim, but rather that they could not rely on fortification to establish eligibility for the claim. ​

“For example, we support fortification of foods bearing the healthy claim to the extent that fortification is used to contribute shortfall nutrients to otherwise nutrient‐dense foods (such as the addition of calcium to 100% orange juice, folic acid to whole‐grain cereal, and vitamins A and D to non‐fat milk) or to meet a standard of identity (such as products containing enriched grains). ​

"Any fortification should be in accordance with FDA’s fortification policy which, among other provisions, does not consider it appropriate to fortify sugars or snack foods such as candies and carbonated beverages.”​

“We believe that food production systems ultimately impact the quality and characteristics of food, and accordingly, it would be appropriate to consider such factors when defining the term “healthy” in food labeling.​

“Going forward, OTA would like to encourage FDA to consider ways to incorporate the contribution of organic production practices and their impact on the quality and characteristics of food into your discussions on the use of the term “healthy” in the labeling of food products.”​

Organic Trade Association (OTA)​

Food labeling regulations​ ​currently mandate that ‘healthy’ can only be used to describe foods with 3g or less total fat and 1g or less saturated fat per serving (excluding fish and meat), while there are also limits on cholesterol and sodium, and minimum requirements for nutrients to encourage (vitamin A, C, calcium, iron, protein, or fiber).

There are no limits on sugar - added or otherwise.

However, FDA now says that​​ it will not enforce current regulatory requirements for products that use the term ‘healthy’ if they:

(1) Are not low in total fat, but have a fat profile makeup of predominantly mono and polyunsaturated fats; or